LR 34 Consultation Paper 2016
18 January 2016
[0116]
Consultation Paper Labelling Review Recommendation 34: Review of mandatory labelling of irradiated food
In 2009, the then Australian and New Zealand Ministerial Council for Food Regulation (now known as the Australia and New Zealand Ministerial Forum on Food Regulation (Forum)) agreed to a comprehensive independent review of food labelling law and policy. An expert panel, chaired by Dr Neal Blewett, AC, undertook the review and the panels final report, Labelling Logic: Review of Food Labelling Law and Policy (2011) (Labelling Logic) was publicly released on 28 January 2011. This consultation is about recommendation 34, one of the 61 recommendations in Labelling Logic. Recommendation 34 states: That the requirement for mandatory labelling of irradiated food be reviewed.
In the government response to recommendation 34, the Forum asked FSANZ to review the need for the mandatory labelling requirement for all irradiated food to continue, and assess whether there is a more effective approach to communicate the safety and benefits of irradiation to consumers. As a first step in analysing the issues associated with recommendation 34, FSANZ is seeking stakeholder views and any relevant information.
To aid submitters in providing comments, questions are provided. Submitters are encouraged to provided comments in response to each question, as appropriate.
For information about making a submission, visit the FSANZ website at information for submitters.
All submissions to the consultation paper will be published on our website. We will not publish material that is provided in-confidence, but will record that such information is held. In-confidence submissions may be subject to release under the provisions of the Freedom of Information Act 1991. Submissions will be published as soon as possible after the end of the public comment period. Where large numbers of documents are involved, FSANZ will make these available on CD, rather than on the website.
Under section 114 of the FSANZ Act, some information provided to FSANZ cannot be disclosed. More information about the disclosure of confidential commercial information is available on the FSANZ website at information for submitters.
Submissions should be made in writing, be marked clearly with the word Submission and quote the correct project number and name. While FSANZ accepts submissions in hard copy to our offices, it is more convenient and quicker to receive submissions electronically through the FSANZ website via the link on documents for public comment. You can also email your submission directly to [email protected].
There is no need to send a hard copy of your submission if you have submitted it by email or via the FSANZ website. FSANZ endeavours to formally acknowledge receipt of submissions within 3 business days.
DEADLINE FOR SUBMISSIONS: 6pm (Canberra time) 29 March 2016
Submissions received after this date will not be considered unless an extension had been given before the closing date. Extensions will only be granted due to extraordinary circumstances during the submission period. Any agreed extension will be notified on the FSANZ website and will apply to all submitters.
Questions about making submissions or the application process can be sent to [email protected].
Hard copy submissions may be sent to one of the following addresses:
Food Standards Australia New ZealandFood Standards Australia New Zealand
PO Box 5423PO Box 10559
KINGSTON ACT 2604The Terrace WELLINGTON 6143
AUSTRALIANEW ZEALAND
Tel +61 2 6271 2222 Tel +64 4 978 5630
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Table of contents
Executive summary4
1Introduction5
1.1Background to recommendation 345
1.2Government response to recommendation 345
2Project approach and scope6
2.1Approach6
2.2Scope7
3Background7
3.1Irradiation as a treatment for food7
3.2Labelling of irradiated food in Australia and New Zealand8
3.3International food irradiation labelling approaches9
4Questions for stakeholders10
4.1Consumer awareness and understanding of food irradiation labels10
4.2Adequacy of current food irradiation labelling requirements12
4.2.1Stakeholder views12
4.3Value of food irradiation labelling13
4.3.1Consumers13
4.3.2Industry15
4.4Approaches to communicate the safety and benefits of food irradiation18
5Next Steps19
6References19
Attachment A Irradiation as a treatment for food21
Attachment B Background to current labelling requirements for Australia and New Zealand26
Attachment C Codex specifications and international requirements for food irradiation labelling for food, and worldwide permissions for food irradiation28
Attachment D Questions for stakeholders33
Executive summary
In 2011 an independent review of food labelling was completed and a final report was publishedLabelling Logic: Review of Food Labelling Law and Policy (2011) (Labelling Logic) (Blewett et al 2011).
The report made 61 recommendations including recommendation 34 which states: That the requirement for mandatory labelling of irradiated food be reviewed.
The Government (through the Australia and New Zealand Ministerial Forum on Food Regulation (Forum)) responded to the recommendations in December 2011. In relation to recommendation 34, the Forum asked FSANZ to review Standard 1.5.3 Irradiation of Food of the Australia New Zealand Food Standards Code, with a view to assessing the need for the mandatory labelling requirement for all irradiated food to continue. The Forum also asked FSANZ to assess whether there is a more effective approach to communicate the safety and benefits of irradiation to consumers.
Consumer exposure to irradiated foods in Australia and New Zealand has, to date, been low and the number of foods permitted to be irradiated has only recently increased. The value consumers currently place on irradiation label information is made in this context and could change as permission for more products to be irradiated is given. The effectiveness of different communication approaches on the safety and benefits of irradiation in the Australian and New Zealand context is difficult to assess given there has been limited education or communication on these subjects.
FSANZ is seeking to characterise the current environment by investigating stakeholder understanding and views on food irradiation labelling, and by identifying economic and technical issues associated with the mandatory labelling requirement.
The information received through this consultation will help FSANZ to better understand the current environment. Submitters are encouraged to respond to the questions in this paper. Background information and our initial consideration of issues relating to recommendation 34 are presented in this paper to help stakeholders prepare submissions.
The Forum did not ask FSANZ to change Standard 1.5.3, so no changes to the Standard are being proposed at this time. In addition, the Forum explicitly excluded the pre-market safety assessment requirement from this review.
After submissions are received FSANZ will prepare a review report for the FSANZ Board. Subject to FSANZ Board approval, the review report will be submitted to the Food Regulation Standing Committee and then to the Forum for consideration in late 2016. If FSANZ is asked to consider amending Standard 1.5.3, any proposed change would be subject to public consultation as part of the formal proposal process.
1Introduction1.1Background to recommendation 34
In 2009, the then Australian and New Zealand Ministerial Council for Food Regulation (now known as the Australia and New Zealand Ministerial Forum on Food Regulation (Forum)) agreed to a comprehensive independent review of food labelling law and policy. The review included extensive public consultation to identify and prioritise labelling elements of concern. An expert panel, chaired by Dr Neal Blewett AC, undertook the review and the panels final report, Labelling Logic: Review of Food Labelling Law and Policy (2011) (Labelling Logic)[footnoteRef:2], was publicly released on 28 January 2011. [2: Labelling Logic is available at: http://www.foodlabellingreview.gov.au/internet/foodlabelling/publishing.nsf/content/home]
Recommendation 34 from Labelling Logic states: That the requirement for mandatory labelling of irradiated food be reviewed.
The labelling review panel noted that the mandatory labelling of irradiated food should be reviewed because foods treated with ionising radiation have been in the food supply for at least 30 years with no evidence of detrimental effects, and there has not been any convincing evidence published to indicate potential future harm to humans.
Labelling Logic cites a 1999 World Health Organization (WHO) Technical Report (WHO 1999) into food irradiation, which concluded that irradiated food (at any dose appropriate to achieve the intended technological objective) is safe to consume and nutritionally adequate. The labelling review panel noted that subsequent to the release of the WHO Technical Report, its conclusions have not been controverted and have been widely endorsed by international and national bodies.
The labelling review panel also noted recommendation 28, which stated that, as a general principle, all food processed by new technologies (including irradiation as a treatment) should be required to be labelled for 30 years from the time of their introduction into the human food chain. The labelling review panel stated that at the e
